Sigman v. Sigman, 2012 Ohio 5433

Laurie Sigman appeals a Wayne County divorce decree entered after a magistrate’s decision.
Marriage lasted 10 years; in 2010 a final hearing occurred and a magistrate recommended spousal support of $200/mo for 24 months, debt allocation favoring Husband, and a $5,506 equalization payment to Wife.
The trial court sustained Husband’s objections to spousal support and debt allocation, eliminated the $5,506 payment, and entered a decree with no spousal support.
Wife appealed; this Court remanded for Civ.R. 75 compliance and a new decree reflecting the rulings; the subsequent decree again denied spousal support.
On review, the Court affirmed the trial court’s disposition; both assignments of error were overruled.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the property division was equitable	Sigman argues the court erred by not adopting the magistrate’s equalization payment.	Sigman contends the trial court’s removal of the $5,506 payment was necessary to achieve equity.	No abuse; division deemed equitable under totality of circumstances.
Whether spousal support was appropriate	Sigman argues spousal support of $200/mo for 24 months is warranted.	Sigman contends there was no basis to award spousal support.	Not warranted; trial court did not abuse discretion under R.C. 3105.18.

Kalail v. Dave Walter, Inc., 9th Dist. No. 22817, 2006-Ohio-157 (2006) (trial court’s property division discretionary; abuse of discretion standard)
Blakemore v. Blakemore, 5 Ohio St.3d 217, 1983 () (abuse of discretion requires unreasonable, arbitrary or unconscionable conduct)
Cherry v. Cherry, 66 Ohio St.2d 348, (1981) () (guides equitable division in divorce; inform review)
Briganti v. Briganti, 9 Ohio St.3d 220, 1984 () (equitable division framework; totality of circumstances)
Jelen v. Jelen, 86 Ohio App.3d 199, (1st Dist.1993) (1993) (importance of considering all factors in R.C. 3105.171(F))